OPINION
SIMPSON, Judge:
Our present consideration of this case arises by reason of the respondent's motion to dismiss the case for lack of jurisdiction on the ground that the petition was not timely filed.
The respondent mailed the notice of deficiency to the petitioners on September 18, 1970. At that time, Mrs. Winkler was a resident of the Principality of Monaco, and Mr. Winkler was deceased. The parties agree that the applicable period...
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